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Extraction Summary

7
People
2
Organizations
1
Locations
1
Events
0
Relationships
3
Quotes

Document Information

Type: Legal document
File Size: 760 KB
Summary

This legal document, filed on April 16, 2021, is a portion of a legal argument defending an indictment against a motion to dismiss. The argument asserts that using pseudonyms for minor victims and providing an approximate date range (1994-1997) for the alleged crimes is legally sound, citing precedents like Stringer, Kidd, and Stavroulakis. It further argues the defendant is not prejudiced, as the government has provided and will provide specific details, such as victim birth information and witness names, during discovery.

People (7)

Name Role Context
Marrero Judge
Cited as the judge who denied a motion to dismiss in the Stringer case.
Stringer Defendant
A defendant in a cited legal case (Stringer's holding).
Kidd Defendant
A defendant in a cited legal case.
Stavroulakis
Name associated with a cited legal case (Stavroulakis, 952 F.2d at 693).
Tramunti
Name associated with a legal case quoted within the Stavroulakis citation.
Nersesian Defendant
Defendant in the cited case United States v. Nersesian.
Vickers Defendant
Defendant in the cited case United States v. Vickers.

Organizations (2)

Name Type Context
Government government agency
Mentioned as having provided discovery and promising to provide witness names.
Courts in the Second Circuit Judicial Body
Mentioned as having consistently upheld indictments with a range of time rather than a specific date.

Timeline (1 events)

between 1994 and 1997
The defendant allegedly engaged in a continuing course of conduct involving the enticement and transportation of minors with intent to commit illegal sex acts, as well as conspiracies to do so.
defendant minor victims

Locations (1)

Location Context
Referenced as the jurisdiction where courts have upheld certain types of indictments.

Key Quotes (3)

"that the identity of a victim was not required to be contained in an indictment, despite the centrality of the victim’s identity to the charge"
Source
— Judge Marrero (From the holding in the Stringer case, found by Judge Marrero, regarding victim identity in indictments.)
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Quote #1
"state[s] the time and place (in approximate terms)"
Source
— Stavroulakis case (Describing what an indictment does, quoted from the Stavroulakis case.)
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Quote #2
"[Th]e Second Circuit routinely upholds the ‘on or about’ language used to describe the window of when a violation occurred."
Source
— Kidd case (A quote from the Kidd case citation, explaining the Second Circuit's stance on using approximate timeframes in indictments.)
DOJ-OGR-00003115.jpg
Quote #3

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